Taxes Consolidation Act 1997 section 790D

Imputed distribution from certain funds

Section 790D provides for a regime of imputed distributions from approved retirement funds, vested personal retirement savings accounts and vested pan-European personal pension products, applying from 2012 onwards.

  • An imputed distribution (the "specified amount") is calculated annually on the value of assets held in an individual's ARFs, vested PRSAs and vested PEPPs on 30 November, at a rate of 4%, 5% or 6% depending on the individual's age and the size of the fund, less actual distributions made during the year.
  • The regime applies where the individual is aged 60 or over for the whole of a tax year, to ARFs created on or after 6 April 2000 and PRSAs vested on or after 7 November 2002.
  • Where funds are managed by different qualifying fund managers, PRSA administrators or PEPP providers, a nominee must be appointed if the combined fund value exceeds €2 million; the appointment is optional if the value is €2 million or less.
  • The imputed distribution is treated as having been distributed or made available not later than the end of February of the tax year following the year for which the specified amount is determined, and the qualifying fund manager must deduct tax and pay it by 14 March of that year.

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